In Gur corporation's case the issue before an English court was whether the Government of Ciskei could…

In Gur Corporation v Trust Bank of Africa (1987) the Court of Appeal allowed Ciskei, an unrecognised entity, to sue by applying the "Doctrine of acts of a delegated sovereign", treating it as a subordinate body exercising authority delegated by South Africa. The Foreign Corporations Act came only in 1991, and neither the "Foreign Relations Act." nor the "Estrada doctrine" was the basis.